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Recreational Boat Manufacturer Factory
Visit Program
by Richard Vance Kanehl
U.S. Coast Guard Office of Boating Safety
Introduction
As of 2003, the Coast Guard Recreational Boat
Manufacturer Identification Code Database (uscgboating.org/recalls/mic_database.htm)
indicates approximately 4,000 in-business recreational boat
manufacturers and importers. This number has remained relatively
stable with an influx and loss of approximately 8% of the
boat manufacturers each year. The Recreational Boating Product
Assurance Division of the Coast Guard Office of Boating Safety
is responsible for overseeing the implementation, maintenance,
and enforcement of Federal recreational boat safety regulations.
The Factory Visit Program is the primary method for the Office
of Boating Safety to ensure recreational boat manufacturers
are complying with the safety regulations.
Background
In August 1971, Congress passed the Federal
Boat Safety Act. Among other things, this act authorized the
Coast Guard to establish national construction and performance
standards for manufacturers of recreational boats, and to
develop enforcement mechanisms. This includes (as listed in
33 CFR §179-181) the display of capacity information,
safe loading, safe powering and flotation standards for monohull
boats of less than 20 feet in length, except sailboats, canoes,
kayaks, and inflatables. The Coast Guard has also published
standards covering electrical, fuel and ventilation systems
applicable to all boats with permanently installed gasoline
engines.
From the early 1970s to the mid-1980s, boat
manufacturing safety regulations were enforced by personnel
from Coast Guard District Offices. From 1988-1995, designated
Coast Guard military and civilian personnel from the Marine
Safety and Inspection Offices assumed these responsibilities.
In 1995, the Coast Guard decided that factory visits would
only be conducted when there was evidence that a boat, or
its components, contained a defect which could cause an injury
or death.
For the next several years, the factory visits
were only conducted on an as-needed basis. However, organizations
such as BOAT/US and the American Boat & Yacht Council
(ABYC), expressed concerns to Congress that this arrangement
was inadequate to ensure recreational boat construction safety
standards. As a result, the Transportation Equity Act for
the 21st Century “TEA-21”, directed the Coast
Guard Office of Boating Safety to revise and strengthen the
recreational boat compliance programs.
As the Factory Visit Program
is not necessarily inherently governmental work, it was renewed
as a Pilot-Program in 2001 with a private contractor. Factory
visits are now completed by “Compliance Associates”
who have an extensive background in boat construction standards.
The Compliance Associates have also received training from
the American Boat & Yacht Council to ensure standardization
of procedures and knowledge of Federal regulations.
Since many manufacturers have not been
visited in several years, the primary emphasis of the Pilot-Program
has been to substantiate the nation-wide boat building and
importer industry, and to ensure their basic compliance with
the boating safety standards. It is important to note that
the emphasis of the Factory Visit Program has been to provide
education and guidance on how to build safer boats, rather
than compliance enforcement.
Typical Factory Visit
A typical factory visit is a comprehensive effort
toward educating boat manufacturers in Federal safety regulations.
The local Compliance Associate prepares for each visit by
writing to the boat builder or importer to provide an explanation
of the program and to make an appointment. Upon arriving at
the facility, the Compliance Associate asks to see the plant,
the construction process and current boat production. During
an examination of current production, the Compliance Associate
looks for:
a) non-compliance with Federal regulations
involving safety standards applicable to the boat manufacturer,
b) incorrect installation of equipment, such
as navigation lights, according to Federal regulations,
and
c) construction practices that differ from
recognized voluntary industry safety standards.
Once the factory visit is completed, violations
of Federal regulations are identified. Potential non-compliance
items that cannot be confirmed by inspection—such as
safe loading figures that appear too large or insufficient
flotation material—are discussed, and management's calculations
and test procedures are reviewed.
When possible, foam and other component samples
are obtained. A test lab, contracted by the Coast Guard, subjects
these products—along with boats bought on the open market—to
more extensive evaluations ensuring their proper performance
and adherence to performance standards.
Violations of the Federal regulations are discussed
with the manufacturer and voluntary compliance is encouraged
to increase boating safety, as well as to help create good
customer relations. Practices related to voluntary industry
standards are also discussed. The manufacturer receives a
written report of all noted violations.
Types of Factory Visits
There are two main types of factory visits:
Inspection Factory Visit: This
occurs when a boat manufacturer or importer has a vessel on
the premises, available for inspection. Boats are reviewed
for compliance with the Federal Regulations that are applicable
to that type of boat. The individual components, such as flotation
material, fuel lines, construction drawings and mandatory
records are also reviewed.
Education Factory Visit: While
many manufacturers have boats on-site, some build-to-order
or use just-in-time delivery thereby minimizing the potential
that a boat will be available for review. New manufacturers
may not have completed, or even begun, boat construction efforts.
When this occurs, the Compliance Associate completes an Education
Factory Visit. Even if a completed vessel is not available,
boat builders still view this type of visit as being of much
value. Not only are immediate questions answered, but they
gain a resource for future situations where assistance to
understand or interpret a regulation ensures a product line
is in compliance with Federal safety regulations. Prior review
of procedures and plans can also prevent costly mistakes before
construction begins.
Accomplishments
Since 2001, the Factory Visit Program has conducted
more than 3,500, factory visits at recreational boat manufacturing
and importation facilities throughout the United Sates. Most
of these visits have focused on boat manufacturers that are
subject to Federal safety standards. Manufacturers of boats
not subject to Federal safety standards, e.g., sailboats,
canoes, kayaks and inflatables, are visited less frequently.
Conclusion
With the renewed Factory Visit Program, the
Coast Guard has greatly increased the certified percentage
of boats that are compliant with Federal safety regulations,
thereby increasing the overall safety of recreational boats.
The Pilot-Program, from 2001 until present, concentrated on
providing all boat builders with a basic level of understanding
of the Federal safety regulations.
Starting in 2004, there will be an even greater
emphasis on assisting boat builders with more complex problems
and how to incorporate proven safety enhancement measures.
Educational materials, such as a CD-Rom containing an easy-to-understand
interpretive guides of the regulations, will provide every
level of boat builder with a more comprehensive understanding
of different ways to build better and safer boats for the
United States recreational boating public.
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